Cominter Wine - Wine trading company

INFORMATION WITHIN THE MEANING OF ART. 13-14 GDPR (GENERAL DATA PROTECTION REGULATION) 2016/679

Cominter Wine s.r.l. with registered office in Via Roma, 98 - 23868 Valmadrera (LC), VAT number 01862130133 (hereinafter "Holder"), as data controller, informs you pursuant to art. 13 EU Regulation n. 2016/679 (hereinafter, "GDPR") that your data will be processed in the manner and for the following purposes:

1. Object of the Treatment

The Data Controller processes personal data, such as name, surname, company name, address, telephone number, e-mail address, bank and payment details - hereinafter, "personal data" or even "data") that you have communicated in on the conclusion of contracts for the services of the Owner.

2. Purpose of the processing

Your personal data are processed:

A) without your express consent (Article 6 letter b), e) GDPR), for the following Service Purposes: - conclude contracts for the services of the Data Controller; - fulfill the pre-contractual, contractual and tax obligations deriving from relations with you in existence; - fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as for anti-money laundering); - exercise the rights of the owner, for example the right to defense in court; B) only subject to your specific and distinct consent (Article 7 of the GDPR), for the following Marketing Purposes: - to send you via e-mail, post and / or text messages and / or telephone contacts, newsletters, commercial communications and / or advertising material on products or services offered by the Owner and recognition of the degree of satisfaction with the quality of services; - send via e-mail, mail and / or sms and / or telephone contacts commercial and / or promotional communications of third parties (for example, business partners, etc ...). Please note that if you are already our users, we can send you commercial communications relating to services and products of the Owner similar to those already used, save your dissent. 3. Processing methods

The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and / or automated processing. The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 5 years from the termination of the Service Finality relationship and for no more than 10 years from the collection of data for the Marketing Purposes.

4. Access to data

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B): - to employees and collaborators of the Data Controller in Italy and abroad, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators; - to third-party companies or other subjects (by way of example, credit institutions, professional firms, consultants, etc.) who carry out outsourcing activities on behalf of the Data Controller, in their capacity as external data processors.

5. Communication of data

Without the need for express consent (pursuant to Article 6 letters b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies, Judicial Authorities, as well as to those subjects to whom the communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controllers. Your information will not be disseminated.

6. Data transfer

Personal data is stored on servers located within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of the provision of data and consequences of refusal to reply

The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we can not guarantee the services of the art. 2.A). The provision of data for the purposes referred to in art. 2.B) is optional. You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material concerning the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in art. 2.A).

8. Rights of the interested party

In your capacity as an interested party, you have the rights set forth in art. 15 GDPR and precisely the rights to: I. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in intelligible form;

II. obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, the managers and the designated representative pursuant to art. 28, paragraph 3, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents;

III. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment is it proves impossible or involves a use of means manifestly disproportionate to the protected right;

IV. to object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication. Where applicable, it also has the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority. 9. How to exercise rights

You can exercise your rights at any time by sending:
- a registered letter a.r. in Cominter Wine s.r.l. with registered office in Via Roma, 98 - 23868 Valmadrera (LC)
- an e-mail to info@cominterwine.com

10. Information on cookies

In order to make its services as efficient and easy as possible to use Cominter Wine s.r.l. can make use of cookies, which are small files that, when the user visits the website or the mobile application, are saved in the browser directory User's device web. The cookies that can be used by Cominter Wine s.r.l. serve to improve the user's use of the services offered because: - they allow you to navigate efficiently from one page to another of the website; - memorize the preferences entered by the user; - allow you to avoid entering the same information (such as username and password) several times during the same visit. - measure the use of the services by the USER, to optimize the browsing experience and the services themselves. The installation of cookies and other tracking systems operated by third parties operating on the web can not be technically controlled; therefore, any specific reference to cookies and tracking systems installed by third party web operators that is expressly present on the website and / or on the mobile application is to be considered merely indicative. Whenever on the web pages manage by Cominter Wine s.r.l., traffic analysis services and tracking of records such as Google Analytics or other tools of other web operators, the user, to view the related privacy information and to avoid any tracking, must use the appropriate tools made available by that specific web operator.